ML20125D881

Responds to 850518 Request for Meeting Re Nuclear Svcs Corp Audit of Pullman-Kellogg Piping Work at Plant in 1977.Late Jul Suggested to Meet for Informal Discussion

ML20125D881
Person / Time
Site:	Diablo Canyon
Issue date:	05/31/1984
From:	Naymark S QUADREX CORP.
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20125D664	List: ML20125D660 ML20125D687 ML20125D703 ML20125D742 ML20125D756 ML20125D790 ML20125D811 ML20125D863 ML20125D881 ML20125D897 ML20125D909 ML20125D924 ML20125D943 ML20127B734 ML20127B742 ML20127B746
References
FOIA-84-740 NUDOCS 8506120495
Download: ML20125D881 (1)

Text

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s Quadrex Corporation 1700 Deli Avenue. ComODell. CClifom C 95005-6986 408 866 4510 TWX 910 590 243E TELEX 35-2031 TELECOPY 408 370-4391 Sherman Noymork President May 31, 1984 Nunzio J. Palladino Chairman United States-Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Chairman:

I am in receipt -of your letter of May 18 wherein the Commission has requested personal discussions with .me to develop a..better understanding of the Nuclear

. Services Corporation audit of the - Pullman-Kellogg -

piping work at the Diablo -Canyon Plant in-1977. -

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I could meet with the Commission at a mstudlly conve- ~

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nient time ~ to , talk informally on ;this' issue , 'if it"is ~

,your desire. I .would suggest. a date _in ,. late ~ July since prior corp 6 rate commitments and an overseas trip will not allow a Washington visit before that --

date. . -

Please advise me of an acceptable date for an informal discussion. -

Sincerely, _

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8506120495 850201 g3' PDR FOIA DEVINEB4-740 PDR

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g g Copy placed in DiablO Canycn File w/backgrTr.d S,

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May 18, 1984 CHAIR MAN Dr. Sherman Naymark President, Quadrex Corporation 1700 Dell Avenue Campbell, California 95008

Dear Dr. Naymark:

The Commission has received your letter of April 9,1984, in which you responded to the invitation extended to you by our Region Y Administrator to address us on_ matters related to-the Nuclear Service Corporation audit of the Pullman-Kellogg Company in 1977.

You letter persuasively states that.a number of years have passed since that audit, and your records and the current unavailability of employees originally ~ involved in the audit make it difficult to reconstruct details.

Nevertheless, we believe that personal discussions with you would assist us in. developing a better understanding of that issue. Therefore, the Comitis-sion would like to re'p eat its invitation for you to meet with us on this subject in the near future. Please advise me of your decis. ion.

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> Nunzio . Palladino ec: Mr. L.'M. Gustafson

Pacific Gas & Electric Co. -

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f April 9,1984

- Mr . J. 3. Ma rti n -

Regionni Administrator U.S. Nucles.: Regulatory Cec =;ission, Region V i 1450 Maria L.an e, Suite 210 .

W inut Creek CA 94596 Dea r Mr . Ma rti rn .,,

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Over the fee days, members of your s ts.ff and you have conrocre.d .past ma with respect to the cuality assurance audit that

! Quadrex Corporation. - formerly Nuclect Se rvi c es Corporation (ESC),- performed fur the Full man-Kellogg Company in August-September 1977. Thi s audit covered Pullman's pi and erection work ut..?GandE's Diable Canyon Faci $ninE constru: tion tty. Additional-ly, your letter to me of April 4. 1984, s=pple=ented rhe prior telephone- conversations we had and asked if Quadrex could reviev repor.ts of the NRC audit.(7.eport Nos 50-275/83-37 and 50-323/83-25 dated February 29, 1986) which reviewed Quadrex's gudit dated October 27,- 1977, and i f we vould determine the

iessons for the different findings of the two reports.

inf o rmstion , Quadrcx vos contracted by Pull =an-Tor Relloga backgroun$ PK 'try August of 1977 to perform an audit of the ?K perforE.an(ce )at the Diablo Conyon Kuclear Facility. An abbrevi-i ated audit was requested which commenced on August 22. 1977, at the Dicblo Canyon. site and~ extended through September 20, 1977, i eith 3 to e cuul.ity assurance engineers from Quadrex participat-i int. Since th'e audit scope was g catly limited by the client as

to' time, funds, and investigatt ve. scope and.was an "ir!-pro

ess" sudit taking a snapshot. look at :.he QA proccoures ano cocumenta-tien r.ade av'a il able to the auditors by the. client, the findings were based only en - presented documentation plus some interviews l

4 vith appropriate ?K PeoP le- .

Quadrex manu gement revi ewed the initial audit findings shortly final repcrt befero after the audi. started und al s o .h e t rcnsmi t ral . Quadrcx menc r.,cment directed .i t s cedit tegn to r pe,r t its ' findings di re:tly Lc ellent's r.ac.agement and Nandl proceeded,

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nogement as the audit as well as in its final j nuh.:ittal , 30 that thin client would be fully cognicant of our

fi ndi ngs at . the cerliest time, and also of the reccrds bein5 -

_,~.m ,w ,audi':ed on which the finding,s were based. ,

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?tge 2 April 9, icB4 P.r . .) . 1!. tiartin After our audit ens subr.i tted en the clien:, we believe there  ;

vere reviews of its contents by Pullman-Kellogg and ?GendE, but we do not have records to indicate that reports of any of these reviews or subsequent actions were supplied to us.

has jus: completed a You have advi s ed Quadrex that the 1GC r evi.aw of the NSC audit and n:te =any findings at vs.rience with va.s made in late 1983 and 1984 to cur report. Your reviev i nf ormati on , documentation, and personnel interviews made avail-able to you et Cne time.-

You have asked if Quadrcx can review the recent h7C findings, compara them to the 1977 NSC findi ngs and discuss the differ-ences. You have also asked i f I would appear before a Co=missien hearing vir.h this evaluatien or any other responses.

Quadrex' perf ormed the i nI ti al nudi t under eon:rac: to PK with PGendF.'s approval. The resul t s were based on information made available to us by the clien: a: that time. The findings .were reviewed' with the 'c-lient as the' audit progressed and when of :he final reocrt was issued. We have not been' advised any cctiens she client or PGandE took a.s a consequence of the audii:

findings , 'n=r in the normal course of completing the constru:-

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tien v=rk. Therefore, we are not aware of how the 1977 condi-tiens have changed in the intcrim peri od nor of any additional pcrtinent documentation that has been gathered responsive to the issues rai sed. i ;

Quadrex is n1so' not. cognir. ant that the same information was cvsilabl e for review by both parties (seven years apart),

whe:her the same interviews were held, and what the differences '

were in the respective audi:nts' reconstituting the ' original evaluation of the presented 6:te. To do .:hEs vnuld recuire and re-evaluating the nn equivalent o.n e ,

e:hnical team, or i ncluding any addi:icnal data gathered by PK, ce=:,a reb] e date',

si:er the 1977 audit was compl e t ed , as they did their own review of the Quadrex findings. The three principa.1 auditors ehe' di d the verk in 1977 nre not now in the c= ploy of Quad:cx l and their availability would have to be established. 0:., another eteam cf Quadrex auditors coul datad be consti tuted which would have and evaluati=ns of both teams,

ace the presented l :n

c us '.nt in;; the.selves by reference end int ervi ews with the earlier auditers' wcyk.

Cuadrex bcs not been requested to undertake this effert by its nor would we undertake this r-fgtnal client .or by ?GendE, ef f e.rt' withcut odecuate enntractural arran5ements acceptable to 3'.. :he part?c.s involved.

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, Mr. J. 3. P.artin Page 3 Kpril 9,1954 Quadrex cennot, t.herc.Eore , at this time' add substantive inferma-tien .at a Cc= mission hazzing regarding the dif:erences in tne sudi t.s cenducted by different teams many intervening yez;s and conditions snart. On t.h at basis, e see no merit. to apper. ring or testifyind at the April 1984 Co=y, =:.s s:.=n hearings ,

t Sincercly ygurs,

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